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Sanctions: "Academy" pays USD1.7m penalty for providing tuition services. Apparently. Potentially.

Friday, 13 February, 2026 - 07:52

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced a USD1,720,000 settlement with IMG Academy, LLC to settle its potential civil liability for 89 apparent violations (breaches) of OFAC counternarcotics sanctions.

If that all sounds a bit vague, wait until you see what the company (allegedly?) did. 

Between 2019 and 2025, IMG Academy dealt in the property or interests in property of two Specially Designated Nationals (SDNs) sanctioned for their ties to a sanctioned Mexico-based drug cartel. Specifically, IMG Academy entered into yearly tuition agreements with the SDNs and received and processed payments pursuant to those agreements. The settlement amount reflects OFAC's determination that IMG Academy's conduct was non-egregious and not voluntarily disclosed.

IMG Academy, a school and athletics training facility headquartered in Bradenton, Florida, has agreed to pay $1,720,000 to settle its potential civil liability for apparent violations of OFAC counternarcotics sanctions. Over five consecutive years, IMG Academy repeatedly transacted with two individuals whom OFAC sanctioned based upon their ties to a sanctioned Mexican-based drug cartel.

Background and Description of the Apparent Violations


IMG Academy offers elite academic and sports training opportunities to U.S. and international student-athletes through full-time boarding school programs, professional training schemes, camps, online coaching services and college sports recruiting resources. IMG Academy’s student body includes athletes from all over the world and it has recruiting offices or representatives in Mexico, China, Japan, and South Korea.


Between 2018 and 2022, IMG Academy entered into yearly contracts, in the form of tuition enrolment agreements (TEAs or “agreements”), with two Specially Designated National (SDN) individuals—hereafter “SDN 1” and “SDN 2,” or “the SDNs” collectively—sanctioned under the Foreign Narcotics Kingpin Designation Act for providing financial support and services to a sanctioned Mexican Drug Trafficking Organization (DTO) and/or to its principal leader. IMG Academy also received and processed tuition and related payments pursuant to these agreements throughout the course of its relationship with the SDNs. These agreements and transactions were undertaken for the enrolment and attendance of the SDNs’ two student-athlete children.

 


The question of school fees was raised in "How not to be a money launderer" by Nigel Morris-Cotterill in 1996.

Find out more of what this seminal financial crime risk focused book set out long before others started to talk about "The Risk Based Approach"

Click here for information on how to buy a personalised PDF of the original print files. 

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